1. Information you give us (Client Supplied Data): You may give us information about you by filling in forms on NoviCap website and/or Platform, for example when you register as a user of the Platform, register your billing details to become a customer, open a support request, post on our blog, take part in competitions, prize draws or surveys, fill out forms, or by corresponding with us by phone, e-mail or otherwise. The information you give us may include your name, e-mail address, employment details, phone number and billing address.

2. Information we may automatically collect about you (Automatic Device Data): With regard to each of your visits to the Platform we may automatically collect the following information:

Visit information - including the full URL clickstream to, through and from the Platform (including date and time), page response times, errors, length of visits to certain pages, page interaction information, actions taken within the application and methods used to navigate away from the page;

3. Information from other sources (Other Data): We are working closely with third parties (including, for example, business partners, sub-contractors in technical and payment services, intelligence providers and analytics providers) and may receive information about you from them.

The above types of information may not always contain personal data (i.e. data which identifies a person). Some of this information may instead contain non-personal data (i.e. data that does not identify you). As non-personal data is anonymous, this privacy policy does not restrict or limit our use and disclosure of non-personal data.

Our site uses cookies to distinguish you from other users of our sites. This helps us to provide you with a good experience when you browse our sites and also allows us to improve our sites. By continuing to browse the sites, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our sites. They include, for example, cookies that enable you to log into secure areas of our sites.

Strictly necessary cookies. These are cookies that are required for the operation of our sites. They include, for example, cookies that enable you to log into secure areas of our sites.

Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our sites when they are using it. This helps us to improve the way our sites work, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies. These are used to recognise you when you return to our sites. This enables us to personalise our content for you, greet you by name and remember your preferences.

Targeting cookies. These cookies record your visit to our sites, the pages you have visited and the links you have followed. We will use this information to make our sites and the advertising displayed on them more relevant to your interests. We may also share this information with third parties for this purpose.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our sites.

HOW DO WE USE PERSONAL DATA?

We may process personal data in connection with the following purposes:

Client Supplied Data

to provide you with information and services that you request or contract to;

to bill and collect money owed to us by our Clients;

to update our records and generally maintain your account with us;

to provide you with special offers, promotions, surveys and other information about services we feel may interest you, where you consent to receiving such information;

to notify you about changes to this privacy policy and other terms that you have agreed to;

for research and development purposes to evaluate and enhance the Platform; and

to deal with your queries, complaints or concerns,

to evaluate your eligibility for one or more of our financial products

Automatic Device Data

to provide our service to you;

to present content from the Platform in an effective manner to you;

to administer the Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

as part of our efforts to keep the Platform safe and secure;

to enforce compliance with our Terms of Service and applicable law;

to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and

to make suggestions and recommendations to you and other users of our site about services that may interest you or them,

Other Data

to evaluate our client relationships, or potential client relationships, and the benefit, or potential benefit, obtained from the Platform;

we may also combine this information with the above information and use this information for the purposes set out above.

to use a combination of all available data provided and collected to be used for algorithmic and statistical processing as it relates to providing novicap’s services.

to use all available data to make automated decisions on eligibility and continued access to our services.

We shall not process personal data for any other purpose, unless such purpose is expressly communicated to you at the point your personal data is being collected.

We store the data for as long as there is a designated purpose, a legal requirement or if none of the former up-to 6 years.

DIRECT MARKETING - HOW TO UNSUBSCRIBE

If you have consented to receive marketing communications from us via email you can change your mind and withdraw that consent. You can opt-out by clicking on the Unsubscribe link at the bottom of the email you’ve received or updating your user account settings. Alternatively, you can send an email to customer service at privacy@novicap.com or if you are a platform user, login to your account and withdraw consent for direct marketing.

LEGAL BASIS

The legal basis for which we act as Data Controller are as follows:

GDPR Article 6(1)(a) - processing of your personal data is based on consent given by you, for a specific purpose as defined above.

GDPR Article 6(1)(c) - processing of your personal data is necessary for compliance with a legal obligation. Specifically, this relates to AML/KYC, financial and accountability data

GDPR Article 6(1)(f) - processing of your personal data is necessary for legitimate interests of both NoviCap and you as our customer. Specifically:

Ensuing NoviCap’s systems are secure and for the purposes of performance and error monitoring and incident response

Improving the performance and user experience of the NoviCap product

determining your eligibility for our financial product

RIGHT OF ACCESS AND RECTIFICATION

The GDPR gives you the right to access and request a correction of personal data held about you. Your right of access can be exercised in accordance with the GDPR. Some access requests may be subject to a reasonable fee to meet our costs in providing you with details of the personal data we hold about you.

You have the right to access and correct your personal information. If you want to review or correct your personal information, you can send us an email at privacy@novicap.com to exercise this right. NoviCap may request additional identification documents to verify your identity.

RIGHT TO DELETE PERSONAL DATA

You have the right to request deletion of personal information we hold about you and we have the obligation to erase your personal information, where:

the personal information is no longer necessary in relation to the purposes for which it was collected or otherwise processed,

you withdraw consent on which the processing is based and where there is no other legal ground for the processing,

you object to the processing and there are no overriding legitimate grounds for the processing,

the personal information has been unlawfully processed, or

the personal information has to be erased for compliance with a legal obligation in the European Union.

If you want to request removal of your personal information from our Websites or Services, you may send us an email at the address noted in the Contact Information section above. You can also request closure of your account. We will respond to your request within 30 days. NoviCap may request additional identification documents to verify your identity.

RIGHT TO OBJECT TO AUTOMATED INDIVIDUAL DECISION MAKING

You have the right to object to automated decision making based on your personal information where the legal basis for the processing is based on Art.6.(1)(f)

You have the right to object to automated decision making based on your personal information where the legal basis for the processing is based on Art.6.(1)(f)

If you want to object to our automated algorithmic processing, you may send us an email at the address noted in the Contact Information section above. NoviCap may request additional identification documents to verify your identity.

RIGHT TO DATA PORTABILITY

In some cases, we may not be able to remove your personal information, in which case we will let you know that we are unable to do so and why.

You have the right to receive or transfer a copy of your personal information, where:

we are relying upon your consent or the fact that the processing is necessary for the performance of a contract to which you are party as the legal basis for the processing, and

personal information is processed by automatic means.

This copy will be provided to you in a common machine-readable format. You may also require us to transmit it to another party where this is technically feasible.

If you want to request a copy of your personal information, you may send us an email at the address noted in the Contact Information section above. NoviCap may request additional identification documents to verify your identity.

RIGHT TO RESTRICT PERSONAL INFORMATION PROCESSING

You have the right to request the restriction of processing of your personal information, where:

you contest the accuracy of the personal information until we take sufficient steps to correct or verify its accuracy,

where the processing is unlawful but you do not want us to erase the personal information, or

where we no longer need the personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims

Where personal information is subjected to restriction in this way we will only process it with your consent or for the establishment, exercise, or defence of legal claims. This right includes restricting the processing of your personal information to only include storage of your personal information (e.g. during the time when NoviCap assesses whether you are entitled to have personal information erased).

If you want to request restriction of processing of your personal information, you may send us an email at the address noted in the Contact Information section above. You can also request closure of your account. We will respond to your request within 30 days. NoviCap may request additional identification documents to verify your identity.

RIGHT TO WITHDRAW CONSENT

Where you have provided us with your consent to process personal information, you have the right to withdraw such consent at any time.

You can do this by:

using certain web browser and opt-out options discussed in this Privacy Policy to limit the personal information you provide to us or our third-party partners,

login to the platform, if you are a platform user, and withdraw consent,

send us an email at support@novicap.com,

following the unsubscribe instructions included in emails,

When withdrawing consent through unidentified channels, we may request additional documentation to ascertain your identity.

RIGHT TO SUBMIT COMPLAINTS OR REPORT ABUSE

You also have the right to lodge a complaint with a supervisory authority, in particular in your country of residence, if you consider that the processing of your personal information infringes applicable laws.

If you need to report abuse, you may send us an email at the address noted in the Contact Information section above.

ACCEPTABLE USE POLICY

You may not use any of our services and products to:

Do anything illegal or otherwise breach the law.

Threaten, harass, or violate the privacy rights of others; send unsolicited communications; or intercept, monitor, or modify communications not intended for you.

Harm users such as by using viruses, spyware or malware, worms, trojan horses, time bombs or any other such malicious codes or instructions.